Tag Archives: Pesticide

By Amanda Rigdon

In my last column, I took a refreshing step out of the weeds of the specifics behind cannabis analyses and took a broader, less technical look at the cannabis industry. I had envisioned The Nerd Perspective being filled with profound insights that I have had in the cannabis industry, but I have realized that if I restricted this column to insights most would consider profound…well…there would not be many articles. So in this article, I want to share an insight with you, but not one that is earth shattering. Instead, I want to talk about a simple concept in a way that might help you think a little differently about the results your lab generates, the results you have to pay for or even the results printed on a cannabis product you might purchase.

This article is all about the simple concept of concentration – the expression of how much of something there is in relation to something else. We use expressions of concentration all the time – calories per serving, percent alcohol in beer, even poll results in the presidential election circus. Cannabis is not excluded from our flippant use of concentration terms – percent cannabinoid content, parts-per-million (ppm) residual solvents, and parts-per-billion (ppb) pesticides. Most of us know the definition of percent, ppm, and ppb, and we use these terms all the time when discussing cannabis analytical methods. During my career in analytical chemistry, it has occurred to me that parts per billion is a really infinitesimal amount…I know that intellectually, but I have never tried to actually visualize it. So being the nerd that I am, I went about comparing these often-used concentration terms visually in my kitchen.

I started by preparing a 1% solution of food coloring paste in water. This was accomplished by weighing out 5g of the food coloring and dissolving it into 500mL of water (about one teaspoon into a pint). The resulting solution was so dark it was almost black:

The picture above expresses the low end of what we care about in terms of cannabinoid concentration and a pretty normal value for a high-concentration terpene in cannabis.

I then took one teaspoon of that mixture and dissolved it into 1.32 gallons of water (5mL into 5000mL), resulting in a 10ppm solution of green food coloring in water:

I did not expect the resulting solution to be so light colored given the almost-black starting solution, but I did dilute the solution one thousand times. To put this into perspective, 10ppm is well above many state regulatory levels for benzene in a cannabis concentrate.

I then took one teaspoon of the almost-colorless 10ppm solution and dissolved that into another 1.32 gallons of water, resulting in a very boring-looking 10ppb solution of green food coloring in water:

Obviously, since I diluted the almost-colorless 10ppm solution a thousand times, the green food coloring cannot be seen in the picture above. As a reference, 10ppb is on the low end of some regulations for pesticides in food matrices, including – possibly – cannabis. I know the above picture is not really very compelling, so let’s think in terms of mass. The picture above shows eleven pounds of water. That eleven pounds of water contains 50 micrograms of food coloring…the weight of a single grain of sand.

To expand on the mass idea, let’s take a look at the total mass of cannabis sold legally in Colorado in 2015 – all 251,469 pounds of it. To express just how staggeringly small the figure of 10ppb is, if we assume that all of that cannabis was contaminated with 10ppb of abamectin, the total mass of abamectin in that huge amount of cannabis would be just 1.143g – less than half the mass of a penny.

To me, that is an extremely compelling picture. The fact is there are instruments available that can measure such infinitesimal concentrations. What’s more, these tiny concentrations can be measured in the presence of relatively massive amounts of other compounds – cannabinoids, terpenes, sugars, fats – that are always present in any given cannabis sample. The point I’d like to make is that the accurate measurement of trace amounts of cannabis contaminants including pesticides and residual solvents is an astounding feat that borders on magical. This feat is not magic though. It requires extremely delicate instrumentation, ultra-pure reagents, expert analysts, and labor-intensive sample preparation. It is far from trivial, and unlike magic, requires a large investment on the part of the laboratories performing this feat of science. Other industries have embraced this reality, and the cannabis industry is well on its way toward that end…hopefully this article will help put the job of the cannabis analytical lab into perspective.

October 5, 2016

Colorado Rule Changes Increase Costs for Edibles Producers

By Aaron G. Biros

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Cannabis processors and dispensaries in Colorado were hit with new rule changes over the weekend, going into effect on October 1^st. The rule changes affect those producing edibles and dispensaries that sell retail and medical cannabis products.

The universal symbol required on all cannabis products in Colorado

As of October 1^st, all cannabis edibles must be marked with the universal THC symbol, according to a bulletin posted by the Colorado Department of Revenue’s Marijuana Enforcement Division (MED). Both medical and retail cannabis products require labeling that includes a potency statement and a contaminant testing statement.

The rules also set “sales equivalency requirements” which essentially means a resident or non-resident at least 21 years of age can purchase up to one ounce of cannabis flower or up to 80 ten-milligram servings of THC or 8 grams of concentrate, according to the MED. The packaging must also include: “Contains Marijuana. Keep out of the reach of children.”

The universal symbol printed on products from Love's Oven. — The universal symbol printed on products from Love’s Oven.

It seems that cannabis edible manufacturers have two clear choices for complying with the new rule requiring the THC symbol: They can use a mold to imprint the symbol on their product or they can use edible ink. Peggy Moore, board chair of the Cannabis Business Alliance and owner of Love’s Oven, a Denver-based manufacturer of cannabis baked goods, uses edible ink to mark each individual serving. The printer uses similar technology and ink used to print on m&m’s, according to Moore. “Baked goods are difficult to find a solution for marking them because they are a porous product, not smooth.” Complying with the new rules almost certainly means added costs for processors and edibles producers.

Moore said she updated all of their labels to include the appropriate information in compliance with the rules. “In terms of regulatory compliance, there have been some disparities for labeling and testing requirements between medical and retail cannabis products, however they are coming into alignment now,” says Moore. “The testing statement rule has been in place for some time on the retail side, but now we are seeing this aligned with both medical and retail markets.” This new rule change could be seen as a baby step in making the different markets’ regulations more consistent.

September 14, 2016

Automated Solutions for Cannabis Laboratories: Part I

By Danielle Mackowsky

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rsz_96_well_plate-1-1 — Using well plates for dSPE sorbents can help expedite sample clean up.

Sample volume remains to be the primary influence on whether an automated solution is a logical investment for a cannabis testing facility. Due to both the complexity of the material being tested and the extraction approach at hand, it may be difficult to find an automated platform that can fully accommodate your laboratory’s needs. Hamilton Robotics in collaboration with United Chemical Technologies (UCT) has developed a solution that allows for automation of specific sample clean up steps commonly utilized in cannabis pesticide testing schemes. The MPE² Positive Pressure Extraction/Evaporation Module is a standalone manifold that can also be incorporated into a number of automated liquid handling decks. Used in tandem with dispersive solid phase extraction (dSPE) salts/sorbents packed into a 96 well plate, this combination provides laboratories with high throughput extraction convenience with comparable results to traditional dSPE for the analysis of over forty pesticides.

As states continue to expand testing requirements for pesticides, it is vital that your laboratory is equipped with a method that allows versatility for the addition of new compounds without burdening your extraction team. There are a variety of dSPE salt and sorbent blends readily available that have been optimized for cannabis extractions. This allows for the use of a reliable extraction technique that can be adapted for the automation age. Hamilton is widely recognized throughout both clinical and forensic laboratory settings and the MPE² platform is an excellent first system for laboratories beginning to automate/semi-automate their processes.

MPE2 Positive Pressure Extraction/Evaporation Module

Following an initial QuEChERS extraction, additional cleanup is typically recommended for extracts that are being analyzed for pesticide content due to the low detection limits often required. dSPE provides the necessary sample clean up to obtain those thresholds, but often burdens a laboratory staff with additional time consuming preparation steps. Traditionally, dSPE salts are packed into 2 mL centrifugation tubes that require a cumbersome supernatant pipetting step followed by additional vortex, spin and transfer steps. By packing the dSPE sorbents into a well plate format, the user is able to completely automate this above described clean up ultimately saving time and adding convenience without jeopardizing any recovery data.

For most compounds, the recovery was greater than 65% for both methods of dSPE. The mean recoveries for traditional dSPE were 98.0%, 99.2% and 97.9% at pesticide concentrations of 50 ng/mL, 100 ng/mL and 200 ng/mL, respectively. For comparison, the mean recoveries at the same concentrations for well plate dSPE were 85.0%, 88.9% and 89.1%. Therefore, there was typically about a 10-11% absolute difference in recovery between the two methods, which can be corrected for by implementing the use of internal standards. When comparing the recovery differences between the two methods, there are six compounds with noticeably larger discrepancies across all three concentrations, namely: chlorpyrifos, cyprodinil, diazinon, spinetoram, spiromesifen 278 and trifloxystrobin. If these data sets are excluded, then the average absolute differences in recovery between the two methods decrease to 8.8%, 6.4% and 5.8% for concentrations of 50 ng/mL, 100 ng/mL and 200 ng/mL, respectively.

Overall, laboratories can estimate on saving 40-60 minutes per 96 samples processed using the Hamilton MPE² in conjunction with a UCT dSPE plate. When a liquid handling robot is also available, this time saving estimation is potentially doubled. Time spent per sample, including the training of laboratory scientists, is an important factor to consider when setting up your laboratory. Automation is in an investment that can greatly reduce a laboratory’s overall labor costs in the long run.

September 12, 2016

Oregon Cannabis Lab Accreditation Program Gets Help, Problems Addressed

By Aaron G. Biros

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Last week, news of problems facing Oregon’s cannabis laboratory accreditation program surfaced, leading some to speculate about possible delays for the recreational cannabis market. According to The Register-Guard, ORELAP administrator Gary Ward believed the program was “on the precipice of collapse.”

According to Jonathan Modie, spokesman for the Oregon Health Authority (OHA), the Oregon Environmental Laboratory Accreditation Program (ORELAP) was anticipating over 30 cannabis laboratories applying for accreditation and they doubled their staff from two to four to prepare for the uptick in applications.

In June, the agency had zero labs applying for accreditation but within two months, 37 labs applied. However, the Oregon Department of Environmental Quality (DEQ) just provided three additional staff members on Monday to help with the application process, says Modie.

Some believe the issues could mean the state may not have enough accredited labs by October 1^st, when the recreational cannabis market is expected to go into full swing. “It is difficult to say exactly how many labs we can accredit by October 1,” says Modie. “We have seven labs today which would bring it to nine labs waiting for assessment, but our goal is to get as many labs assessed and hopefully accredited as soon as possible.”

With the additional staff members, Modie is hopeful this will jumpstart the program. “We really appreciate our collaboration with the DEQ and look forward to boosting our capacity a bit to help us get through this busy time,” says Modie.

Part of the reason some laboratories might have trouble meeting prerequisites is simply because the requirements are very strict. “The process involves submitting a quality manual, standard operating procedures, method validation, submitting proficiency testing data and finally undergoing an ORELAP assessment by our staff, so it is a very rigorous process,” says Modie. “This speaks to our concern for making sure they have the right systems in place so public health is protected.” Modie said there were at least three labs that did not pass the assessment.

Roger Voelker, lab director at OG Analytical

Bethany Sherman, chief executive officer of OG Analytical, believes the hardest part of the process involves getting accredited for testing pesticides. OG Analytical, based in Eugene, Oregon, has already received their accreditation, one of the first to do so. “The pesticide testing requires our most expensive instrumentation and the sample preparation for testing pesticides is the most time consuming,” says Sherman. “Not only does it require very specific instrumentation, it also requires a real know-how and expertise to ensure we are cleaning samples appropriately, minimizing background noise and looking at the pesticides in trace quantities.” According to Sherman, laboratories are also left to their own devices to develop methodologies specifically for the cannabis matrix, adding to the difficulties.

Rodger Voelker, Ph.D., lab director at OG Analytical, seems confident that the state will be able to handle it. “It is a relief they were able to get some resources from the DEQ and I think the state will not allow a program with this kind of importance to fall apart,” says Voelker. He believes after this initial phase of putting the program in place, the workload will go down. “It is easier to maintain a program than it is to implement,“ adds Voelker. In his eyes, it is crucial for the program to require rigorous science. “People are forced to reconcile that there is a tremendous amount of controls to be considered to produce legally defensible data and I think it is great that the requirements are so strict.”

The OHA’s job is to essentially safeguard public health and they do not want to leave any stone unturned when it comes to potential contamination, says Modie. “This is not just about getting as many labs accredited as possible, this is about protecting public health.”

August 17, 2016

Sustainability for the Cannabis Industry, Part II: The New Cannabis Consumer

By Olivia L. Dubreuil, Esq., Brett Giddings

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Most readers ought to be well aware that the cannabis industry is rapidly growing. The Arcview Group, an Oakland-based investor network, estimates the retail and wholesale cannabis market will reach $22.8 billion by 2020. That number represents a lot of people consuming cannabis in many different ways.

The average cannabis consumer is changing. A new range of social groups is consuming cannabis-based products. From yoga diehards, to middle-aged men and women, veterans that have ‘tried everything else’ and young professionals looking for a different way to relax, the market is broadening.

This new segment of cannabis consumers are often not looking to get high- they are looking for anti-inflammatories, relaxants and ways of dealing with chronic pains and stress. For these health and wellness seekers, the last thing they want is a product dosed with pesticides, insecticides or butane residues. We can expect to see these consumers to follow broader consumption trends- specifically when it comes to a product like cannabis that people are inevitably placing in or on their bodies.

These consumers come with new sets of expectations, similar to those when they buy fruit, vegetables, coffee or chocolate. They are increasingly curious about the contents of the products they purchase- they are a large part of the reason that the sales of organic produce has ‘ballooned’. They are asking questions like: Does the product contain pesticides? Has the product been cultivated in a way that minimizes negative environmental impacts? How do we know that the supply chain quality controls are rigorous enough to ensure no one has tampered with the product? Who is growing and picking this product and how are those people being treated?

When a curious consumer enters a modern American supermarket, they are guided by a range of messages relating to the contents and supply chain that was part of making each product. Organic, non-GMO, pesticide-free, fair trade, free-range and locally produced are some of the common criteria. The more credible labels are supported by codes and procedures in which the whole supply chain is audited, monitored and approved by the certifying body according to certain standards- for example the USDA certifies organic foods.

Being a Schedule I controlled substance under federal law, cannabis is probably not going to receive USDA organic certification any time soon. However there are organizations out there that are committed to increasing the availability of cannabis grown with organic practices. Certifying bodies like Certified Kind and the Organic Cannabis Growers Society are gaining popularity among growers who see the market evolving in that direction. At the same time, businesses such as Delicious Fog (an ‘organic-focussed’ delivery service in Santa Clara County) and Harvest (an ‘organic’ dispensary in San Francisco)- are specializing in the sale of these ‘organic’ cannabis products.

Just like any sustainability issue- ensuring your cannabis product comes from a well-managed supply chain cannot be a last minute add-on. Whether a business is small, large, mature or emerging, developing a strategic approach to the diverse spread of sustainability challenges is critical.

As a cannabis business what can you do to appeal to the new cannabis consumer?

June 1, 2016

Pesticide & Potency Analysis of Street-Grade versus Medicinal Cannabis

By Danielle Mackowsky

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In states where cannabis is legalized, some analytical laboratories are tasked with identifying and quantifying pesticide content in plant material. This is a relatively new concept in the study of cannabis as most forensic laboratories that work with seized plant material are only concerned with positively identifying the sample as cannabis. Laboratories of this nature, often associated with police departments, the office of the chief medical examiner or the local department of public health are not required to identify the amount of THC and other cannabinoids in the plant. While data is abundant that compares the average THC content in today’s recreational cannabis to that commonly consumed in the 1960s and 1970s, limited scientific studies can be found that discuss the pesticide content in street-grade cannabis.

cannabis-siezed — Street-grade cannabis that is ground into a fine powder

Using the QuEChERS approach, which is the industry gold-standard in food analysis for pesticides, a comparison study was carried out to analyze the pesticide and cannabinoid content in street-grade cannabis versus medicinal cannabis. For all samples, one gram of plant material was ground into a fine powder prior to hydration with methanol. The sample was then ready to be placed into an extraction tube, along with 10 mL of acetonitrile and one pouch of QuEChERS salts. After a quick vortex, all samples were then shaken for 1 minute using a SPEX Geno/Grinder prior to centrifugation.

Quenchers-analysis — Formation of layers following QuEChERS extraction

For pesticide analysis, a one mL aliquot of the top organic layer was then subjected to additional dispersive solid phase extraction (dSPE) clean-up. The blend of dSPE salts was selected to optimize the removal of chlorophyll and other interfering compounds from the plant material without compromising the recovery of any planar pesticides. Shaken and centrifuged under the same conditions as described above, an aliquot of the organic layer was then transferred to an auto-sampler vial and diluted with deionized water. Cannabinoid analysis required serial dilutions between 200 to 2000 times, depending on the individual sample. Both pesticide and cannabinoid separation was carried out on a UCT Selectra® Aqueous C18 HPLC column and guard column coupled to a Thermo Scientific Dionex UltiMate 3000 LC System/ TSQ Vantage^TM tandem MS.

Pesticide Results

Due to inconsistent regulations among states that have legalized medicinal or recreational cannabis, a wide panel of commonly encountered pesticides was selected for this application. DEET, recognized by the EPA as not evoking health concerns to the general public when applied topically, was found on all medical cannabis samples tested. An average of 28 ng/g of DEET was found on medicinal samples analyzed. Limited research as to possible side effects, if any, of having this pesticide present within volatilized medical-grade product is available. Street-grade cannabis was found to have a variety of pesticides at concentrations higher than what was observed in the medical-grade product.

Potency Results

Tetrahydrocannabinolic acid A (THCA-A) is the non-psychoactive precursor to THC. Within fresh plant material, up to 90% of available THC is found in this form. Under intense heating such as when cannabis is smoked, THCA-A is progressively decarboxylated to the psychoactive THC form. Due to possible therapeutic qualities of this compound, medical cannabis samples specifically were tested for this analyte in addition to other cannabinoids. On average, 17% of the total weight in each medical cannabis sample came from the presence of THCA-A. In both medical and recreational samples, the percentage of THC contribution ranged from 0.9-1.7.

Summary

A fast and effective method was developed for the determination of pesticide residues and cannabis potency in recreational and medical cannabis samples. Pesticide residues and cannabinoids were extracted using the UCT QuEChERS approach, followed by either additional cleanup using a blend of dSPE sorbents for pesticide analysis, or serial dilutions for cannabinoid potency testing.

May 18, 2016

Solutions for Cannabis Cultivation: Integrated Pest Management

By Aaron G. Biros

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Pest problems in cultivating cannabis such as spider mites and powdery mildew are major concerns facing growers on a daily basis. Colorado’s ongoing recalls for cannabis products containing pesticides serve as a reminder that pest problems continue to plague growers. Utilizing integrated pest management (IPM) can help reduce the need to use any pesticides, as well as mitigate the risk of unwanted pests wreaking havoc on a cannabis harvest. urban-gro, a solutions provider for commercial cannabis cultivation, builds IPM plans for large-scale cannabis growers tailored to meet specific needs in regulatory compliance for different states.

Biological controls are essential to any proper IPM solution for growers. Beneficial living organisms such as insects, mites, nematodes or entomopathogenic fungi can all be applied as a method for controlling pests. Biological controls like those can reduce the need to use pesticides on cannabis. John Chandler, vice president of cultivation technologies at urban-gro, believes IPM requires a broad, systematic approach to eliminate the need for pesticides. “IPM is a combination of cultural, chemical and biological control,” says Chandler. “We start by evaluating the air flow of the facility, how plants are transported, any exclusion barriers and air filtration.” A robust IPM plan begins in the design phase of a new facility. “We can make key adjustments in floor plans, layouts and mechanical systems to optimize that first line of defense that is critical to mitigating the risk of pest issues.” Incorporating good agricultural practices can also help mitigate those risks.

durangopot — A close-up of a plant entering flowering at the Durango facility

“We help develop standard operating procedures with good agricultural practices in mind, including preventing cross contamination, which is the biggest pest issue facing cannabis growers,” says Chandler. “I encourage clients to set up harvest and vegetative rooms so that the plants are moving in one specific direction between rooms rather than back and forth.” Using positive air pressure with proper ventilation can further prevent cross contamination. Chandler also recommends scrubbing air coming into the building with gaseous hydrogen peroxide to keep filtering air in ventilation.

According to Mark Doherty, director of sales at urban-gro, their IPM plans are customized to meet different states’ rules and regulations, including each list of approved pesticides. “We work to design a system that meets each individual grower’s needs, while helping them navigate regulations in any given state,” says Doherty. “It is important to make cannabis safe for patients and IPM is critical in building a healthy ecosystem for plants to be grown in a safe, yet cost-effective manner.” Proper use of IPM can reduce the need to use pesticides, which could impact a cultivator’s bottom line, but ultimately protect patients’ wellbeing by providing safe and pesticide-free cannabis.

prosodic — Procidic works on contact and with residual action.

When all else fails and pests still find their way onto cannabis, there is a solution to address major losses. urban-gro distributes a product called Procidic2®, a broad-spectrum bactericide and fungicide compound, manufactured by Greenspire Global. The advanced commercial formula is designed to eliminate pathogenic bacteria and fungi. Procidic2® can be applied as a preventive and a curative. WSDA Organic Program has approved Procidic2® for use in organic agriculture production and handling. According to Steve Knauss, president of Greenspire Global, “Procidic2® works in sync with the plant through two modes of action: First it controls powdery mildew and gray mold on contact, and secondly it is absorbed systemically into the plant to control disease infection such as root rot,” says Knauss.

Implementing a comprehensive IPM system requires making key changes in cultural, biological and chemical controls. In doing so, growers can successfully mitigate the risk of pest problems, thus reducing the need for potentially harmful pesticides.

April 28, 2016

Biros' Blog

Ongoing Pesticide Recalls a Sign of Industry Maturity

By Aaron G. Biros

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Regulators in Colorado last week announced another massive recall of cannabis found to contain banned pesticides. 92 batches of cannabis plants, with roughly a dozen plants in each batch, were recalled for using the product, Guardian, on the plants. The culprit was an ingredient in the product called avermectin, a pesticide listed as a ‘bad actor’ by the Pesticide Action Network.

The recall follows dozens of others in Colorado this year, all because tests found pesticides present in cannabis samples. When news spreads of cannabis recalls due to concerns of pesticide contamination, it paints a picture of worrisome problems rampant in the cannabis industry. Alarmists say continued recalls could have disastrous consequences like stalling legalization initiatives or slowing growth in new markets.

In the food industry, recalls are a part of routine business. The FDA created the Reportable Food Registry (RFR) as a way to prevent the shipment of contaminated food products into the supply. In 2015, Chipotle Mexican Grill made news when it sickened dozens with an E.coli outbreak and issued extensive recalls as a result. After that happened, the company reevaluated its practices and improved their food safety program to prevent future outbreaks.

When a recall occurs, it should prompt a surge in inquiries, responses and audits that need to be addressed and reviewed carefully. Ample proactive planning including HACCP, comprehensive risk analysis and validation studies or documents help prevent recalls from occurring in the first place. When recalls do happen, reactive measures should occur immediately with a strategy in place to deal with all of the regulatory compliance, quality, safety and branding ramifications.

When a recall occurs in the food industry, it generally means that there was a foodborne illness outbreak, followed by a reactive measure. That reactive measure, the recall itself, is what prevents foodborne illness outbreaks from growing or becoming an epidemic. Recalls in the food industry show that regulators are concerned about contamination and taking action to safeguard public health. In other words, when a recall occurs, it means that someone is watching.

I think recalls in the cannabis industry are a sign of the marketplace growing up. Recalls can be seen as a good thing, a sign of proper safety measures in place to prevent further contamination. Reporting recalls or failures means that professionals are beginning to pay attention to the safety and quality of processes in place at cannabis production facilities. Looking at the long-term sustainability of the cannabis industry, keeping quality and safety at top of mind will help businesses self-legitimize. Those not striving for the safest practices and the best quality will lose their ability to compete as the market continues to grow. Recalls can tarnish a company’s brand, but they also indicate that the industry has reached a point of legitimacy. Cannabis is now out of the closet and under a microscope.

April 5, 2016

Biros' Blog

The Cannabis Industry’s Pesticide Problem

By Aaron G. Biros

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Colorado regulators recalled roughly 65 batches of cannabis produced by two separate companies last Friday. Pesticide recalls plastered all over the news in the past few months have painted a picture of the cannabis marketplace to the public as unsafe and lacking crucial quality standards. The continued pesticide recalls in Colorado, along with poor safety standards in Washington, show the cannabis industry in an unfavorable light. The recalls include not only cannabis sold recreationally, but also medical cannabis, which should highlight a sense of urgency to deal with such a pervasive issue.

Because patients with weakened immune systems are seeking treatment with cannabis, it is the producer’s obligation to grow cannabis safely and without pesticides. That requires proper quality controls, pesticide use standard operating procedures, very robust lab testing and an overall push to protect consumer safety from both regulators and industry leaders.

The pesticides most commonly found in cannabis products include myclobutanil, a fungicide in Eagle 20, and avermectin, commonly found in Avid pesticides. The Pesticide Action Network lists both compounds as “bad actors” and as developmental or reproductive toxins.

Largely due to federal illegality, there are no EPA-approved pesticides for use in cannabis production, thus a lack of guidelines for states to follow in regulating pesticide use. As a result, states are working to write their own lists of approved pesticides.

Until very recently, Washington had no procedure for recalls of cannabis in place. “The LCB in Washington State has implemented emergency recall rules but more clarity on what types of pesticides are harmful is needed,” says Trek Hollnagel, co-founder of Dope Magazine and a chain of dispensaries in Seattle, WA. It is no secret that the Washington State Liquor Cannabis Board (LCB) poorly regulates cannabis labs.

Reports show immense variation in different labs’ results and rampant laboratory shopping. Dana Luce, co-founder of GOAT Labs, Inc., a cannabis-testing laboratory based in Vancouver, Washington, has been clamoring for a standardized recall procedure. “The state needs to take a much more proactive approach in monitoring laboratories,” says Luce. “Using blind testing or secret shoppers would give them the opportunity to catching those labs playing below board.” Luce also believes that retail outlets should absorb the cost of recalls, which could help prevent laboratory shopping just for higher potency test results.

In Washington, regulators rely on producers to self-report coupled with random inspections; furthermore they do not even require pesticide testing. Without a burden of proof placed on the producer or even the laboratory, it is hardly a regulated market.

Those producing cannabis with pesticides listed above should know they are violating the law. According to Comprehensive Cannabis Consulting (3C), “applying pesticides off label is a violation of state and federal law and could result in criminal and civil sanctions…”

In reality, the solution to this problem is not just a quick fix, but a multitude of corrective actions to move the cannabis industry forward. Nic Easley, chief executive officer of 3C, believes it starts with educating cultivators on using pesticides properly and good agricultural practices (GAP). “Many of the pest problems prompting the illegal use of pesticides are due to poor facility design, lack of cleanliness, over-fertilization and other general plant health issues,” says Easley. “All of those issues could be greatly reduced through education in GAP.”

Then comes regulator-industry collaboration, where all parties are constantly learning. “Regulators or independent third-party groups need to be performing on-site inspections, which cultivators need to participate in openly and transparently,” adds Easley. The Colorado Department of Agriculture (CDA) is actively working on this aspect by offering workshops aimed at helping producers get up to speed with worker protection standards.

“Adequate standards need to be applied across the board to labs, and ongoing proficiency testing needs to take place to ensure that a lab’s facility, processes and instruments are fully validated,” says Easley. So the problem is cannabis producers still using pesticides off label and if that continues, so will the recalls. It seems the solution involves industry-regulator collaboration, more robust laboratory systems and calibration methods and educating cultivators on good agricultural practices. Additionally, more state guidance is needed in the form of research for an approved list of pesticides on cannabis and a bigger push for regulation in the form of inspections and laboratory oversight.

April 4, 2016

The Practical Chemist

Easy Ways to Generate Scientifically Sound Data

By Amanda Rigdon

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I have been working with the chemical analysis side of the cannabis industry for about six years, and I have seen tremendous scientific growth on the part of cannabis labs over that time. Based on conversations with labs and the presentations and forums held at cannabis analytical conferences, I have seen the cannabis analytical industry move from asking, “how do we do this analysis?” to asking “how do we do this analysis right?” This change of focus represents a milestone in the cannabis industry; it means the industry is growing up. Growing up is not always easy, and that is being reflected now in a new focus on understanding and addressing key issues such as pesticides in cannabis products, and asking important questions about how regulation of cannabis labs will occur.

While sometimes painful, growth is always good. To support this evolution, we are now focusing on the contribution that laboratories make to the safety of the cannabis consumer through the generation of quality data. Much of this focus has been on ensuring scientifically sound data through regulation. But Restek is neither a regulatory nor an accrediting body. Restek is dedicated to helping analytical chemists in all industries and regulatory environments produce scientifically sound data through education, technical support and expert advice regarding instrumentation and supplies. I have the privilege of supporting the cannabis analytical testing industry with this goal in mind, which is why I decided to write a regular column detailing simple ways analytical laboratories can improve the quality of their chromatographic data right now, in ways that are easy to implement and are cost effective.

Anyone with an instrument can perform chromatographic analysis and generate data. Even though results are generated, these results may not be valid. At the cannabis industry’s current state, no burden of proof is placed on the analytical laboratory regarding the validity of its results, and there are few gatekeepers between those results and the consumer who is making decisions based on them. Even though some chromatographic instruments are super fancy and expensive, the fact is that every chromatographic instrument – regardless of whether it costs ten thousand or a million dollars – is designed to spit out a number. It is up to the chemist to ensure that number is valid.

In the first couple of paragraphs of this article, I used terms to describe ‘good’ data like ‘scientifically-sound’ or ‘quality’, but at the end of the day, the definition of ‘good’ data is valid data. If you take the literal meaning, valid data is justifiable, logically correct data. Many of the laboratories I have had the pleasure of working with over the years are genuinely dedicated to the production of valid results, but they also need to minimize costs in order to remain competitive. The good news is that laboratories can generate valid scientific results without breaking the bank.

In each of my future articles, I will focus on one aspect of valid data generation, such as calibration and internal standards, explore it in practical detail and go over how that aspect can be applied to common cannabis analyses. The techniques I will be writing about are applied in many other industries, both regulated and non-regulated, so regardless of where the regulations in your state end up, you can already have a head start on the analytical portion of compliance. That means you have more time to focus on the inevitable paperwork portion of regulatory compliance – lucky you! Stay tuned for my next column on instrument calibration, which is the foundation for producing quality data. I think it will be the start of a really good series and I am looking forward to writing it.